Daily Archives: September 9, 2026

Addition under Section 56(2)(vii)(b) is unsustainable when Permanent Alternate Accommodation is granted against relinquishing sub-tenancy rights without receipt of possession.

By | September 9, 2026
0 Comment

Addition under Section 56(2)(vii)(b) is unsustainable when Permanent Alternate Accommodation is granted against relinquishing sub-tenancy rights without receipt of possession. Issue Whether an addition under Section 56(2)(vii)(b) can be sustained when the assessee acquired entitlement to Permanent Alternate Accommodation (PAA) directly in consideration for relinquishing existing sub-tenancy/occupancy rights under a redevelopment agreement, and where physical… Read More »

Addition for unexplained loan deleted as identity proven, while undervaluation matter remanded for agreement verification.

By | September 9, 2026
0 Comment

Addition for unexplained loan deleted as identity proven, while undervaluation matter remanded for agreement verification. Issue Unexplained Investments (Section 69): Whether an addition made by the AO under Section 69 on account of an unexplained loan investment is liable to be deleted when the assessee furnished the lender’s PAN, loan confirmation letter, and bank statements… Read More »

EPF/ESI delayed by web portal technical glitches is deductible under Section 36(1)(va).

By | September 9, 2026
0 Comment

EPF/ESI delayed by web portal technical glitches is deductible under Section 36(1)(va). Issue Whether a one-day delay in remitting employee EPF/ESI contributions due to technical glitches and non-availability of the payment gateway/EPFO web portal beyond the assessee’s control constitutes a violation of Section 36(1)(va) disallowing the deduction. Facts Assessee & Assessment Year: The assessee is… Read More »

Registration under Section 12AB cannot be cancelled absent proof of non-genuine activities or statutory violations.

By | September 9, 2026
0 Comment

Registration under Section 12AB cannot be cancelled absent proof of non-genuine activities or statutory violations. Issue Whether CIT(E) can cancel an educational trust’s Section 12AB registration over bank cash deposits, high surplus ratios, or unrecorded leases without proving non-genuine activities or fund diversion. Facts Registration Granted: The assessee-society, running educational institutions, was granted registration under… Read More »

Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination.

By | September 9, 2026
0 Comment

Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination. Issue Whether capacity utilization/economic adjustments under TNMM can be summarily rejected by the TPO without considering past coordinate bench precedents. Whether provisions created in earlier years and treated as operating expenses can be treated as non-operating income upon write-back… Read More »